Identify yourself, your affiliation and a very brief description (title) of the issue.
Dave Neve, chairperson of the American Academy of Actuaries Life Reserves Work Group.
Treatment of Due Premiums in VM-20 reserve calculation

2.

Identify the document, including the date if the document is “released for comment,” and the location in the
document where the amendment is proposed:
VM-20: Requirements for Principle-based Reserves for Life Products, Draft dated 12/2/2012, Sections 2,
6A and 7B.

3.

Show what changes are needed by providing a red-line version of the original verbiage with deletions and
identify the verbiage to be deleted, inserted or changed by providing a red-line (turn on “track changes” in
Word®) version of the verbiage. (You may do this through an attachment.)
See attached document.

4.

State the reason for the proposed amendment? (You may do this through an attachment.)
The current draft of VM-20 is silent on the treatment of due premiums. This proposal clarifies due
premiums as similar to deferred premiums when determining the adjustment for DPA in section 2, and
requires that due premiums be included in the expected future cash flows when calculating the
Deterministic Reserve and Stochastic Reserve. Since this approach reduces the resulting DR and SR
amounts compared to the reserve amounts that would be calculated had there been no due premiums in the
cash flows, it is appropriate to include due premiums along with deferred premiums when making the
comparison of the DR and SR to the NPR.

* This form is not intended for minor corrections, such as formatting, grammar, cross–references or spelling. Those types of changes do not
require action by the entire group and may be submitted via letter or email to the NAIC staff support person for the NAIC group where the
document originated.

NAIC Staff Comments:

Dates: Received

Notes:

Reviewed by Staff

Distributed

Considered

Section 2.

Minimum Reserve

A. All policies subject to these requirements shall be included in one of the groups defined by paragraphs 1, 2
or 3. The company may elect to exclude one or more groups of policies from the stochastic reserve
calculation and the deterministic reserve calculation if the exclusion tests determined pursuant to section 6
are passed. The minimum reserve equals the sum of:
1.

For the group of policies that pass both the stochastic exclusion and the deterministic exclusion test:
the aggregate net premium reserve for those policies.

2.

For the group of policies that pass the stochastic exclusion test but do not pass the deterministic
exclusion test: the aggregate net premium reserve plus the excess, if any, of the deterministic reserve
determined pursuant to Section 4 over the aggregate net premium reserve for those policies reduced by
any deferred premium assetdue and deferred premium asset held on account of those policies.

3.

For the group of policies that fail the stochastic exclusion test, and for the group of policies not subject
to the exclusion tests: the aggregate net premium reserve plus the excess, if any, of the greater of the
deterministic reserve determined pursuant to Section 4 and the stochastic reserve determined pursuant
to Section 5 over the aggregate net premium reserve for those policies reduced by any deferred
premium assetdue and deferred premium asset held on account of those policies.

Section 6.

Stochastic and Deterministic Exclusion Tests

A. Stochastic Exclusion Test
3.

Stochastic Exclusion Demonstration Test
b.

The company may use one of the following or another method acceptable to the commissioner to
demonstrate compliance with subsection 6.A.3.a:
i.

Demonstrate that the greater of the deterministic reserve and the net premium reserve, less
any associated deferred premium assetdue and deferred premium asset, is greater than the
stochastic reserve calculated on a standalone basis.

ii.

Demonstrate that the greater of the deterministic reserve and the net premium reserve, less
any associated deferred premium assetdue and deferred premium asset, is greater than the
scenario reserve that results from each of a sufficient number of adverse deterministic
scenarios.

iii. Demonstrate that the greater of the deterministic reserve and the net premium reserve, less
any associated deferred premium assetdue and deferred premium asset, is greater than the
stochastic reserve calculated on a standalone basis, but using a representative sample of
policies in the stochastic reserve calculations.
iv. Demonstrate that any risk characteristics that would otherwise cause the stochastic reserve
calculated on a standalone basis to exceed greater of the deterministic reserve and the net
premium reserve, less any associated deferred premium assetdue and deferred premium asset,
are not present or have been substantially eliminated through actions such as hedging,
investment strategy, reinsurance, or passing the risk on to the policyholder by contract
provision.

Section 7.

Cash Flow Models

B. General Description of Cash Flow Projections
1.

For the deterministic reserve and for each scenario for the stochastic reserve, the company shall project
cash flows ignoring federal income taxes and reflecting the dynamics of the expected cash flows for
the entire model segment. The company shall reflect the effect of all material product features, both
guaranteed and non-guaranteed. The company shall project cash flows including the following:
a.

Revenues received by the company including gross premiums received from the policyholder
(including any due premiums expected to be collected after the valuation date).